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A Respondent’s Wishlist: 10 Changes Businesses Would Like to See From the New FTC Bureau of Consumer Protection

With a Republican majority soon to be at the helm of the Federal Trade Commission, businesses are watching closely to see whether and how the regulatory landscape will shift. In this post, we break down ten things we, as...more

Update on TSR Amendments and Recordkeeping Requirements

As an update to our earlier blog post detailing the FTC’s amendments to the Telemarketing Sales Rule, the changes have since been published in the Federal Register, with an effective date of May 16, 2024....more

The FTC is Not the Only One Tracking Your Use of Health Information

The FTC has made news recently with its recent enforcement activity regarding companies’ alleged disclosures of consumer health data, as detailed in our recent post FTC to Advertisers: We’re tracking Your Use of Health...more

FTC Attempts End Run to Ban Meta from “Monetizing” Minors’ Data

The FTC took unprecedented action yesterday when it moved to impose what it describes as a “blanket prohibition” preventing the company from monetizing young people’s data. The FTC contends that this prohibition is warranted...more

Is Discrimination “Unfair” Under the UDAP Laws? New Lawsuit Challenges CFPB’s Anti-Discrimination Guidelines

Most people would generally agree that discriminating on the basis of race, color, religion, disability, or similar factors is a bad thing to do – indeed, that it’s “unfair” within the common meaning of the word. It’s also...more

“Dark Patterns” Loom Large in New FTC Staff Report

No, we’re not talking about sinister sewing guides, but rather practices or formats that may manipulate or mislead consumers into taking actions they would not otherwise take. We untangled the topic of so-called “dark...more

The FTC’s Privacy Rulemaking: Broad and Far-Reaching, but Unlikely to Lead to a Rule Anytime Soon

On August 11, the FTC finally launched its “commercial surveillance and data security” rulemaking after many months of hype and speculation about the FTC’s ability to address consumer privacy through its “Mag-Moss” rulemaking...more

A New Era for the FTC and U.S. Privacy? House Reconciliation Bill Would Give the FTC $500 Million to Build a New Privacy Bureau.

As we’ve all been following in the news, the House reconciliation bill to fund “human infrastructure” is still mired in negotiations, ever on the verge of either passing to monumental fanfare, or cratering in failure. Tucked...more

GLBA Safeguards Gets a Makeover: Why it Matters for Businesses with Customer Information

In a much-anticipated announcement last week, the FTC amended the Gramm-Leach-Bliley Act (GLBA) Safeguards Rule, and proposed a further amendment requiring certain financial institutions to provide the FTC with notice in the...more

FTC Chair Khan’s Vision for Privacy (Competition, and Big Tech), and Some Dissents

Last week, we wrote about FTC Chair Khan’s memo describing her plans to transform the FTC’s approach to its work. This week, she followed up with a no-less-ambitious statement laying out her vision for data privacy and...more

“Not Outgunned, Just Outmanned” (For Now): Senate Hearing on Privacy Law Addresses Under-resourced FTC

On September 29, 2021, the Senate Commerce Subcommittee held a hearing titled Protecting Consumer Privacy. The senators addressed the potential $1 billion earmarked to strengthen the FTC’s privacy work, the future of a...more

Health and Fitness Apps and IoT Technologies Should Take Note: FTC Expands Interpretation of its Health Breach Notification Rule

In an aggressive expansion of its security and privacy enforcement programs, on September 15, 2021, the FTC issued what it characterized as a “Policy Statement” reinterpreting an old rule about personal health records....more

FTC Continues Push for Civil Penalties with Important Implications for Financial Institutions and MLMs

The FTC yesterday took two actions that on their face seemed part of the regular course, but that could signal notable changes for financial institutions and multi-level marketing companies. First, the FTC filed an amended...more

FTC Nominee Lina Khan Sails through Committee with Bipartisan Support While Chopra Awaits Senate Vote for CFPB Director

The Senate Commerce Committee today voted overwhelmingly to move forward with Lina Khan’s nomination as FTC Commissioner, signaling that Khan is likely to ultimately be confirmed as the youngest Commissioner ever at 32. As...more

What to Expect in Consumer Financial Protection and FinTech in 2021 [Audio]

Often when people think about the Consumer Financial Protection Bureau (CFPB) they say to themselves, “well, I’m not a bank so that doesn't really apply to me.” But consumer financial protection laws are actually much broader...more

Biden Taps Rohit Chopra, Current FTC Commissioner and Vocal Proponent of Aggressive Enforcement, to Lead CFPB

Things are about to change dramatically at the CFPB. President-elect Joe Biden today nominated Rohit Chopra, a current commissioner at the Federal Trade Commission and long-time proponent of aggressive enforcement, to serve...more

FTC COPPA Settlement Shows Ongoing Rift Over Privacy Harm

The FTC’s most recent COPPA enforcement action, announced on June 4 with app developer HyperBeard, provides evidence of an ongoing debate within the Commission about privacy harm and the role of monetary relief in the...more

FCC/FTC Stake out Aggressive Robocall Position, Tell Gateway VoIP Providers to Block COVID-19 Robocalls – or Be Blocked Themselves

The FTC and FCC have taken a number of actions to stem unlawful robocalls generally and, during the COVID-19 pandemic, to stem harmful and deceptive calls that seek to exploit the COVID-19 crisis. Even amid the backdrop of...more

FTC Guidance on AI: Don’t Surprise Consumers – Or Yourself

FTC Bureau of Consumer Protection Director Andrew Smith this week published some helpful pointers for companies that are developing or using AI to support consumer-facing services. These pointers are drawn from past FTC...more

Data Privacy Considerations for Coronavirus Data Tools

Data is helping governments, researchers, and companies across the world track the spread of the novel coronavirus, monitor cases and outcomes of COVID-19, and devise ways to halt the virus’s spread. As part of these...more

FTC Commissioners Share Views on Privacy

FTC Commissioners Rebecca Kelly Slaughter and Christine S. Wilson recently sat down with Cameron Kerry at the Brookings Institution to discuss the FTC’s role in privacy. Although the Commissioners did not agree on everything,...more

Google Presses Pause on Joint Investigation by Agreeing to Record-Setting COPPA Settlement

The FTC and the New York Attorney General recently announced a record-setting $170 million ($136 million to the FTC and $34 million to the NY AG) joint settlement with Google. The settlement resolves allegations that YouTube...more

What Facebook’s Next 20 Years Will Look Like: Is This the Future of US Privacy?

Even in her extensive dissent, FTC Commissioner Rebecca Slaughter labeled the Order “exceptional.” And it is. The terms of the Federal Trade Commission’s (FTC) $5 billion, twenty-year settlement Order reached with...more

Tech Innovation Prompting Revisions to Children’s Privacy Law? FTC Reviewing COPPA Rule and Holding Workshop

The FTC announced today that it is seeking comments on a variety of issues related to the Children’s Online Privacy Protection (COPPA) Rule. Although only six years have passed since the FTC’s 2013 COPPA Rule update, the FTC...more

Time Runs Out for TikTok App: Developer Musical.ly Agrees to FTC’s Largest-Ever Fine for Children’s Privacy Violations

The FTC recently announced a $5.7 million settlement with app developer Musical.ly for COPPA violations associated with its app (now known as TikTok)—the agency’s largest-ever COPPA fine since the enactment of the statute....more

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